Glossary
AI literacy
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Part of: EU AI Act
AI literacy is the skills, knowledge and understanding needed to use AI in an informed way and to recognize its opportunities, risks and harms. Under Art. 4 of the EU AI Act, providers and deployers must take measures to support the development of AI literacy of their staff. This covers every AI system, not only high-risk ones.
In plain English
Think of driver's education. You don't need to be a mechanic to drive safely. You do need to know the rules, how the car behaves on ice and when to brake. AI literacy is the same for AI. It is not coding. It is knowing enough to use AI tools sensibly, spot a hallucination or a biased output, and know what data must never go in.
Different roles need different depth. A board member needs to understand AI risk appetite. A recruiter needs to know how AI can discriminate in hiring. A person reviewing AI outputs needs to recognize automation bias and know when to override.
Example
Penrose Logistics, a fictional EU distributor with 1,800 staff, uses a generative AI assistant and a vendor's route-planning tool. It builds its program in five steps:
- It maps who uses AI, who oversees it and who is affected by it.
- It sets a 45-minute baseline for everyone, including contractors who use its tools. The baseline covers what AI is, hallucinations, the acceptable use policy and how to report a problem.
- It adds role modules. Dispatchers who review AI routes learn about automation bias and overrides. Procurement learns AI due diligence. The board gets a session on risk appetite and oversight.
- It keeps records of who completed what, and tests understanding instead of counting completions.
- It refreshes content whenever tools, policies or laws change.
This is the kind of proportionate measure the current Art. 4 describes. Penrose does not certify that each person reaches a set proficiency level, and the law does not ask it to.
Why it matters
The EU AI Act defines AI literacy in Art. 3(56). It means the skills, knowledge and understanding needed for informed use of AI and awareness of its opportunities, risks and harms.
- Scope: Art. 4 covers providers and deployers of all AI systems, not only high-risk ones. It has applied since 2 Feb 2025.
- The 2026 rewrite: the Digital Omnibus (Regulation (EU) 2026/1744, in force 27 Jul 2026) replaced Art. 4. Providers and deployers now "take measures to support the development of AI literacy" of their staff and others acting on their behalf. The old duty to "ensure, to their best extent, a sufficient level" is gone. The new text expressly does not require them to guarantee any specific level for any individual.
- Support: under the new Art. 4(2), the Commission and Member States must support providers and deployers, especially SMEs. The Commission publishes practical examples.
- Standards: ISO/IEC 42001 separates competence (clause 7.2) from awareness (clause 7.3). The NIST AI RMF expects personnel and partners to receive AI risk management training (GOVERN 2.2).
How the AIGP exam tests it
The BoK asks for training and awareness for all stakeholders (lesson I.B.3), and Art. 4 appears with deployer duties (lesson II.C.6).
Common traps:
- Scope. "Applies only to high-risk systems" or "only to developers" is false. Deployers of any AI system are covered.
- Date. It applied from 2 Feb 2025, alongside the prohibitions, not from 2 Aug 2026.
- Old wording. Answers saying organizations must guarantee a sufficient level for every person reflect the pre-Omnibus text.
- Technical staff only. Risk arises wherever AI outputs are used, so training must reach business users too.
- Completion rates as proof. Attendance is not understanding.
The tell: an organization-wide baseline, deeper role-based modules, records and regular refreshes.
Frequently asked questions
What does Article 4 of the EU AI Act require?
Since the 2026 Digital Omnibus, providers and deployers must take measures to support the development of AI literacy of their staff. This extends to others operating or using AI on their behalf. The measures should reflect people's knowledge, experience, education and training, the context of use and the people affected. No specific level is guaranteed for any individual.
Did the Digital Omnibus change the AI literacy obligation?
Yes. Regulation (EU) 2026/1744, in force from 27 July 2026, replaced Art. 4. The old text required organizations to ensure, to their best extent, a sufficient level of AI literacy. The new text requires measures to support its development and says no specific level must be guaranteed for any individual. The Commission and Member States must help, especially SMEs.
Does AI literacy apply only to high-risk AI systems?
No. Art. 4 applies to providers and deployers of all AI systems, including minimal-risk tools such as a generative AI assistant used for drafting. It has applied since 2 February 2025, the same date as the prohibitions. The 2026 Omnibus changed its wording, not its scope or start date.
Is AI literacy training mandatory under the EU AI Act?
Art. 4 requires measures, but it does not prescribe a format, course length or certificate. Training is the most common measure, alongside guidance, awareness campaigns and role-based coaching. Keeping records of who was trained, on what and when helps an organization show that it took real measures.
Related
Sources
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(5) replacing Art. 4 of the AI Act, EUR-Lex
- EU AI Act Service Desk, Article 4: AI literacy
- Regulation (EU) 2024/1689 (EU AI Act), Arts. 3(56) and 4, EUR-Lex
- ISO/IEC 42001:2023, clauses 7.2 (competence) and 7.3 (awareness)
- NIST AI Risk Management Framework (AI RMF 1.0), GOVERN 2.2